Domicile and Tax Residency for Business Owners: Estate Planning Considerations, Tax Issues, Valuation, and More

Ms. Browning has practiced tax, trusts and estates law with her own characteristic blend of compassion, commitment and legal mastery for twenty years. She is a renowned and respected practitioner and lectures in the areas of trusts and estates, special needs planning, elder law planning, multistate tax issues and charitable gifting.

Mr. Foreman co-chairs FRB’s Taxation Practice Group and advises businesses on the tax effects of a variety of corporate transactions, including taxable and tax-free reorganizations, mergers, sales, and acquisitions. He designs and implements tax-efficient structures for U.S.-based businesses to expand abroad and invest in foreign joint ventures. Mr. Foreman drafts tax memoranda and opinions on a variety of subjects, including tax-free reorganizations, tax-efficient return of capital to owners, Qualified Small Business stock, and various state pass-through entity taxes. He defends clients from audits from the IRS and various state tax agencies, including appealing audit determinations. Mr. Foreman advises clients on a variety of tax issues related to cryptocurrencies, including initial coin offerings (ICOs), taxability of staking and air drops, and the imposition of Sales and Use taxes on the issuance of non-fungible tokens (NFTs). He drafts tax portions of Operating and Shareholder Agreements for businesses in different industries. Mr. Foreman has extensive experience in a variety of SALT issues, especially New York State residency audits and state Sales and Use tax nexus issues post-Wayfair.

Mr. Horowitz focuses his practice on estate, gift, federal income, generation-skipping transfer taxation and related business transactional matters. He provides counsel to businesses and individuals on entity formation, tax-efficient structures, and overall business strategies. Mr. Horowitz has extensive experience in preparing estate planning documents and implementing estate plans ranging from simple wills to complicated domestic and foreign trusts, for asset protection purposes, as well as drafting business transactional documents including purchase and sale agreements, limited liability operating agreements, and other corporate agreements. Mr. Horowitz has experience in international tax advising foreign clients on inbound business and real estate transactions, as well as counseling domestic businesses on outbound foreign business activities. He also works with non-resident aliens on pre-immigration planning.